EHPA would like to thank the European Commission and the study team for the work already carried out and welcome the opportunity given to comment on the recommendations part of the study’s findings. Please find below EHPA positions.
We believe that future clarifications and explanations are necessary before being able to further comments on options. The study is not mature and clear enough to lead to meaningful, understandable, realistic, feasible, measurable, and verifiable policy options. It is EHPA’s understanding that built-in TBS are not in the scope of this study. EHPA does not believe that a horizontal approach for HVAC BACS is appropriate. Finally, EHPA recommends not defining KPI for every BACS level since it depends on the scope.
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